Effective Date 7/31/2018
This Policy covers the policies and practices for how ALICE, an affiliate of FivePals, Inc. (hereinafter referred to as “ALICE,” “we,” or “us”) handles the Personal Data of visitors to our website www.aliceplatform.com (“Website”) and guests of Properties (“guests”) (collectively, “you,” or “your”) who use our web platform, mobile platform, or applications or products that link to this Policy (together, the “Services”). “Personal Data” is information that relates to an identified or identifiable individual.
Information You Provide Directly to Us. When you use the services or engage in certain activities, such as registering, requesting services, or contacting us directly, we may ask you to provide some or all of the following types of information:
Demographic information, such as your gender, ZIP code, year of birth, and details about your personal preferences;
You can choose not to provide information to us directly, but some of this information is required to participate in some Services, such as registering or requesting services from Properties through the ALICE platform.
The best way to protect sensitive data is to not share it. Please do not enter private or sensitive information into the ALICE Services.
Information We Collect Automatically. We may collect certain information automatically through your use of our Services or other methods of web analysis, such as:
Information We obtain from other sources. Properties send ALICE guest information regarding communications, requests, maintenance, and other service delivery. ALICE may also obtain information about you from other third-party services and organizations to enhance your experience.
Additionally, Properties may use additional technologies such as in-room entertainment to send service requests, which may contain Personal Data, to ALICE.
We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a "device") that allow us to record certain pieces of information whenever you visit or interact with our sites, Services, applications, messaging, and tools, and to recognize you across devices.
Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Data. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
The Personal Data we collect depends on the nature of your relationship with us:
In addition, we use the Personal Data that we collect based on the following legal grounds and as necessary and appropriate for the following purposes:
To meet our legal obligations, for example:
Anonymous and Aggregated Information. We may use your Personal Data and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the services, or other analyses.
Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the services. Anonymized or aggregated information is not Personal Data, and we may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes.
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.
Properties. We share Personal Data with Properties you visit, as a byproduct of their using the ALICE platform to communicate with you. We do not control the privacy practices of these Properties, and their information practices are not covered by this Policy. We recommend that you visit the privacy policies of each Property that you visit.
Authorized Third-Party Vendors and Service Providers. We share Personal Data with third-party vendors and service providers that provide business services to us or on our behalf, such as IT services, payment processing services, to market products or services or deliver ads to you, analyze activity on the services, provide content, and help to maintain our user database and administer emails, surveys, or other communications. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders.
We prohibit our service providers from using or sharing your Personal Data except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
Corporate Affiliates. We may share Personal Data with and among corporate affiliates and subsidiaries for their internal business purposes or to provide you with a product or service that you have requested.
Business Transfers. We may share Personal Data in connection with an actual or proposed change in control, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
Legal Purposes. We may disclose Personal Data to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to prevent fraud and to protect and defend the rights, interests, safety, and security of ALICE, our users, or the public.
With Your Consent. We may share Personal Data for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.
If you access third-party services, such as Facebook, Google, or Twitter, through the services to login to the services or to share information about your experience on the services with others, these third-party services may be able to collect information about you, including information about your activity on our websites or through the services, and they may notify your connections on the third-party services about your use of the services, in accordance with their own privacy policies.
Anonymous and Aggregated Information. We may share anonymous or aggregated information within ALICE and with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
ALICE retains the Personal Data we receive as described in this Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
Cookies. You may be able to refuse or disable cookies by adjusting your web browser settings. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). Please note that you may need to take additional steps to refuse or disable local storage and other technologies. If you choose to refuse, disable, or delete these technologies, some of the functionality of the Services may no longer be available to you.
Opting Out. You have the right to opt out of certain uses and disclosures of your Personal Data. Please note, if ALICE collected personal data about you from our Properties or on behalf of our Properties, please direct your query to the Property directly. ALICE will support our Properties as requested within a reasonable timeframe.
If you do not wish to receive marketing communications from us, you may opt out by clicking the “unsubscribe” link within the communication or by contacting us as at email@example.com.
To opt out of other Personal Data processing, contact us at firstname.lastname@example.org.
Interest-Based Advertising. As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/.
Rights of Access, Rectification, Erasure, and Restriction. You may inquire as to whether ALICE is Processing Personal Data about you, request access to Personal Data, and ask that we correct, amend or delete your Personal Data where it is inaccurate. Where otherwise permitted by applicable law, you may contact us as described below to request access to, receive (port), seek rectification, or request erasure of Personal Data held about you by ALICE. Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws.
Although ALICE makes good faith efforts to provide Individuals with access to their Personal Data, there may be circumstances in which ALICE is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If ALICE determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, ALICE will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Data.
California Privacy Rights. California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Data (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Data disclosed to those parties. ALICE does not currently share Personal Data with third parties for their own marketing purposes.
ALICE’s Services are not directed to children under 16 and we do not knowingly collect Personal Data from children under the age of 16 without parental consent, unless permitted by law. If you are under the age of 18, you must have your parent’s permission to access the Services. If you learn that your child has provided us with Personal Data without your consent, you may contact us as described below. If we learn that a child under the age of 16 has provided us with Personal Data, we will delete it in accordance with applicable law.
Some web browsers transmit "do-not-track" signals to websites. Because of differences in how web browsers incorporate and activate this feature, we currently do not take action in response to these signals.
Your rights under the CCPA. The CCPA affords California residents certain rights related to their personal information. You have the right to:
ALICE does not store Credit Card data nor process payments. ALICE utilizes a third-party vault that is responsible for securely storing your credit card data in alignment with information security requirements specified within the PCI DSS.
Your rights under the CCPA. The CCPA affords California residents certain rights related to their personal information. You have the right to:
How do I submit a request to delete my data? Please email your request to: email@example.com.
Opt-out of selling or disclosing your personal information ALICE does not sell or disclose your personal information for monetary gain or any valuable consideration. ALICE provides operations software to hotels and the hotels enter and use your personal information to provide services to you and other guests.
What are the categories of personal information collected? When a hotel uses the ALICE operations software or you engage in certain activities, such as requesting services from the hotel, or contacting the hotel directly, the hotel may ask you to provide some or all of the following types of information:
What is the purpose of collecting my personal information? ALICE does not use the personal information collected by the hotels about you for its own purposes.
If you are accessing the Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States.
The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to help ensure that your privacy is protected.
We utilize Standard Contractual Clauses to ensure that all Persona lData collected in the EU is adequately handled and protected. By using the services and providing us with information, you understand and agree that your information may be transferred to and stored on servers located outside your resident jurisdiction and in the United States by us and the third parties with whom we share it.
We use reasonable measures to help protect information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
ALICE has administrative, physical and technical security measures in place to protect against the loss, misuse, and alteration of the information under our control. We utilize commercially reasonable practices to protect your data.
Contact us with privacy-related questions, complaints, or requests at firstname.lastname@example.org.